New England Dermatology

The covered entity (CE), New England Dermatology P.C., reported that one of its locations, Northampton, improperly disposed of patient records containing protected health information (PHI) by failing to shred them prior to disposal in a dumpster. The PHI included names, mailing addresses, dates of service, and clinical information. The CE provided breach notification to HHS, affected individuals, and the media and also provided substitute notice. Following the breach, the CE implemented a new procedure for disposal of PHI and trained staff on its new compliance procedures. The CE also hired a new business association (BA) to shred all records containing PHI and executed a HIPAA compliant BA agreement. As a result of OCR’s investigation, the CE implemented new policies and procedures.